Outback and in Sight, Used Oil and Safety Glasses or How many lawyers do you know?

What is my responsibility to all these rules and regulations concerning the environment? Safety?

Often on visits to schools and colleges I find some that are unsure of what the requirements are for compliance with EPA and OSHA regulations. Some even think that these federal regulations and state laws do not apply to schools. Well, I would not want to be the instructor or administrator that was responsible for a violation. In the 21st century we are all personally responsible to our society to be aware and protect the environment by being good stewards of our world. When I was a youth dumping used oil and other fluids was considered OK as long as you dumped it somewhere else. Today you and your facility can be held liable for even small oil spills or negligent storage practices. All states consider used oil a hazardous waste and hold the generator of the oil liable for proper storage and disposal. To become a known polluter would be foolish in today’s litigation prone world. Oil storage that is open to rainfall is apt to leak in to the ground water. Oil and fluids stored out in open are hazards to spills however accidental and that makes the person who authorized or was in charge of the materials responsible for their proper storage and safe conduct to the recycle center. I feel the old rule of “CYOA” applies in making sure my shop/lab is in compliance. It is very simple to comply with the regulations. All hazardous materials: used oil, trans fluid, brake fluid, paints, solvents, coolant, batteries and used parts should have a visible closed loop back to a recycling facility or supplier. Nothing from your shop/lab should go to the landfill. Have a spill containment platform with proper storage drums/containers for all fluids. Use a lid or covering with a funnel system that is easy for students to use in transfer of fluids.

Fig#1 This containment pallet and two drums is an inexpensive solution. This needs to be underneath a shed or overhang where rainwater will not collect on drum tops of course. Also, used lead acid batteries may be stored here  until routine collection to a recycle center.

Fig #2, A commercial set for spill and storage containment. www.newpig.com Even this set up would need protective lids and cover from rainfall, high winds and impact damage.

Protecting the individual student

Personal Protective Equipment is required for all persons in contact with hazardous material. This means you and your students, Reference Ga. Code O.C.G.A. § 45-22-2 (all states have similar statements) This means compliance with right to know and MSDS requirements being followed with a documented safety and HazMat training. I will recommend a certificate program like www.sp2.org that will give certification and validate your training of student/employees. This will also cover you in the event of an accident in your lab.

I will never understand the “Push Back” I get from teachers in auto labs that don’t require students to wear safety glasses. Many times I visit otherwise good programs to find students in the lab working without safety glasses. I recently visited a lab and students were grinding metal with air grinders and no PPE or glasses were in use. When asked the instructor replied he had gave up trying to make them wear them. Another teacher said he never wore them at work and did not see the need to make kids wear them. I visited two labs a few years ago with the director and when we observed students working in the lab without safety glasses and I stated the requirement for safety glasses the instructor and the administrator asked me where that rule was as if it were not a common sense practice to protect students from eye injury.

I have a video (Safety Glasses)of students holding a brake clip that had cracked the student’s safety glasses when the clip broke while he was working on the brakes. That is why we call them accidents.

See Georgia School Board Rule (All states have similar rules);

160-4-3-.10

Code : JGF 160-4-3- .10 EYE PROTECTION . (1) REQUIREMENTS . (a) Each local board of education shall adopt a policy for ensuring the safety of every student, teacher and visitor participating in or observing certain courses of instruction in any school . (b) Such policy shall require that persons wear appropriate industrial-quality eye protection equipment at…
http://public.doe.k12.ga.us/…legalservices/160-4-3-.10.pdf

NATEF requires this as a Go-No-Go for accreditation of the program.As always NATEF is the final authority on their standards. Please check with http://www.natef.org for latest updates.

OSHA regulation 29 CFR 1910.132

I will refer you to documents and resources on this page;

https://autoteacher.net/NATEF__Teacher_Helps.html

This is the assumption of the learning environment that NATEF places on Accredited Programs;

http://www.natef.org/documents/auto_standards_2008.pdf

Quote;

12. The concern for safety is paramount to the learning environment. Each program area has the following safety requirement preceding all related tasks:

Comply with personal and environmental safety practices associated with clothing; eye protection; hand tools; power equipment; proper ventilation; and the handling, storage, and disposal of chemicals/materials in accordance with local, state, and federal safety and environmental regulations.

Page 8 “ reference NATEF standards http://www.natef.org

A quick google brings up more information. Here is the summary.

Hazardous Material Storage, includes waste oil, transmission fluid, anti freeze and other automotive fluids. Federal Regulations;

http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&sid=41e1500fdf914c7c862ab38890889e35&rgn=div5&view=text&node=40:26.0.1.1.9&idno=40#40:26.0.1.1.9.3.47.3

PUBLIC LAW 96-463 defines used oil as a hazard to human health.

O.C.G.A. § 12-8-62  (2011) quotes the above law in defining the handling of used oil. All States have similar laws and rules.

All public officials are required to know the laws affecting the workplace they are responsible for. O.C.G.A. § 45-22-2

http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&sid=41e1500fdf914c7c862ab38890889e35&rgn=div5&view=text&node=40:26.0.1.1.9&idno=40#40:26.0.1.1.9.3.47.3

EPA Document; http://www.epa.gov/owow/NPS/ordinance/

Ga Governmental Document http://www.gaepd.org/Files_PDF/techguide/wpb/noiguidance.pdf

Fig # 3 a student with an oil saver he made for use in lab. The drop or two of oil in the bottles is collected in the bucket for recycling in stead of the trash. The plastic bottles are recycled also.

A Resource;

http://www.newpig.com/us/

This company will be pleased to explain the rules, law and regulations that apply to you and your facility. They are qualified experts that can advise on products and their use. I find them easy to work with in understanding EPA and OSHA as it pertains to schools.

If I can be of service to you or your teachers with training, information please let me know. In all these safety issues I would rather be over than under when in comes to meeting the safety issues we all face in our auto labs.

Remember this “It is not about budgets, school boards or facilities but the safety of the individual student as they are in the learning environment you provide” Be aware, Be informed, Be safe!

Sonny Reeves www.autoteacher.net sonnyjreeves@hotmail.com

One Response to “Outback and in Sight, Used Oil and Safety Glasses or How many lawyers do you know?”

  1. Student Safety Issues in the Automotive Lab | Autoteachersonny's Blog Says:

    […] https://autoteachersonny.wordpress.com/2011/05/01/outback-and-in-sight-used-oil-and-safety-glasses-or… […]

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